ML043170303

NRC Comments to the JPM Submittal for the Fermi Initital Exam - September 2004

ML043170303
Person / Time
Site:	Fermi
Issue date:	09/20/2004
From:	Pederson C Division of Reactor Safety III
To:	O'Connor W Detroit Edison
References
50-341/04-301
Download: ML043170303 (1)

Text

FERMI SEPTEMBER 2004 INITIAL LICENSE EXAM JPM COMMENTS

1. Source Comment Resolution

1. JPM B1.a Replace JPM with one with a Safety Function of either 4 or 8, since JPM B1.b Replaced with RBCCW Simulator already has a Safety Function of 2. JPM. Corrected safety Original JPM (SBFW) was replaced due to it being performed during audit. function designation to Replaced with HPCI JPM; however, during validation the HPCI malfunction (8).

did not work. Required facility to find another replacement JPM. New JPM for RBCCW was found acceptable. However, facility noted it as the wrong safety function.

2. JPM B1.b In the Initial Conditions, delete the sentence: Both divisions of Core Spray Changed as Simulator have failed to automatically initiate. recommended..

In the Initiating Cue(s), change ...Division I(II)... to ...Division I.... Changed as recommended.

On the JPM outline, change the Safety Function from 4 to 2, since this JPM is Corrected, changed associated with RPV level control instead of heat removal. Facility error. safety function to (2).

Delete NOTE before step 4 of JPM, and replace with a CUE that says to Changed as acknowledge the malfunction and ask the applicant What do you recommended.

recommend.

3. JPM B1.c During validation noted the setup was incorrect. The speed/load demand Set up corrected.

Simulator limiter was indicating +1 and not IAW JPM task.

Editorial: In the Initial Conditions, correct the typo Perquisites to Changed as Prerequisites. recommended..

Change the following steps so that they are NOT critical: Steps 2, 3, 7, 8, and Changed as 9 (since step 3 is only a verification step and the other steps are NOT recommended.

associated with completing the Task Standard for the JPM.

In step 7, the applicant may refer to procedure 23.610, Section 6.1 (Reactor Changed as Protection System) to reset the half scram. Add steps from procedure 23.610 recommended.

to reset half scram.

4. JPM B1.d Original JPM not discriminating enough. Although it is an immediate action, it Changed as Simulator only has two required steps. However, the very first step is an auto function recommended.

and no operator action is required. Changed JPM so that one is restoring the RR MG Set following maintenance with the scoop tube locked. After Post exam, validation unlocking the scoop tube and going back to AUTO, have the RR flow time appears to be increase in an uncontrolled manner, requiring the scoop tube be locked up incorrect, too long. It again (and the RR MG Set tripped if RR flow increase was greater than 10%). should be Also, make the first step to lock scoop tube not critical for the system will approximately 5 to 6 automatically lock due to the malfunction. minutes and not 15 minutes.

5. JPM B1.e Header and title of the JPM are different. The header was incorrectly noted as Changed as Simulator a different JPM, i.e., B.1.H instead of B.1.e. Also, it was identified as a 2003 recommended.

JPM vice a 2004 JPM.

Remove EDG 11 (12, 13, 14) sentence from initial conditions. Also, only have Changed as 11EA and 64B in the initiating cues and remove sentence of another operator recommended.

will shutdown EDG..

During validation, setup incorrect, also missing page in procedure. Corrected for exam.

Step 3 in JPM is critical. Step 4 is not necessarily critical, unless significant Changed as voltage adjustment is required. recommended.

6. JPM B1.f In the Evaluator Notes, Correct typo of 23.623" to 24.623". Add a Changed as Simulator sentence to ensure the Reactor Mode switch is in SHUTDOWN position. recommended.

In the Initial Conditions, change the second sentence to The reactor has Changed as been shutdown and is in Mode 5. (Information underlined added) recommended.

FERMI SEPTEMBER 2004 INITIAL LICENSE EXAM JPM COMMENTS Header incorrectly notes 2003 JPM vice 2004 was not corrected until post exam.

7. JPM B1.g Change the Initiating Cue to perform manual startup of Division 1 SGTS per Changed as Simulator 23.404 in preparation for RBHVAC fan work. recommended.

In the Evaluator Notes, change the sentence ..., IF the operator asks for Changed as guidance ask for a recommendation. (Information underlined changed) recommended.

Otherwise this would direct the action for the alternate path. Applicant must make the decision, thereby recommending the appropriate actions.

Editorial: Instep 1, change of to or. Changed as recommended.

In step 3, add a NOTE that ARP 8D35, DIV 1 SGTS AIR FLOW STOPPED Changed as annunciator will alarm. The alarm response will require a check of T4600- recommended.

F003A throttled and T4600-F002A open. If the applicant uses the ARP, add a CUE that T4600-F003A is throttled and T4600-F002A is closed. In addition, the reference section noted incorrect ARP 3D35, correct ARP is 8D35.

Delete the CUE before step 4 and replace with the CUE to ask the applicant Changed as What do you recommend. Also, add a NOTE that the applicant may or may recommended.

not shutdown Division 1 SGTS.

On page 3 of JPM: Changed as

- Correct the step numbering from steps 9, 2, and 3 to steps 10, 11, and 12. recommended.

- In new step 11, correct the damper numbers to T4600-F004B, F008B, and F408.

- Change new step 12 to a non-critical step since it is only a verification step.

8. JPM B1.h Original outline noted RWCU and SBFW JPMs as both safety function 2. Changed as Simulator Also, commented that no low power JPM for SROU. Licensee replaced with recommended.

Vent Torus JPM to incorporate additional low power JPM for SROU with different safety function.

After step 2.18 add subsequent steps in procedure to close required valves Changed as when torus pressure is reduced to between 32 and 39 psig. This was noted recommended.

during validation when the setup was not correct for the required Torus pressure. Editorial: Instep 2.5.2 change Guideline to Guideline.

9. JPM B2.i Require applicant to obtain the EOP package. Also, JPM step 2 standard Changed as incorrectly noted the terminal lead B-171. It was the same for step 1. The recommended.

correct lead is E-191.

Validation time appeared to be too long. Actual time for applicants averaged Noted post-exam.

10 minutes, instead of 25 minutes.

Also, updated post-exam, the JPM should note the use of lead boots as supplied in the EOP package.

10. JPM B2.j Noted that this JPM and the original two other in-plant JPM did not enter the Done. Changed the last reactor building. Although all three JPMs were inside the RCA (BWRs in in-plant JPM B2.k to be general everything is within the RCA), they were all within the turbine building. inside reactor building Also, JPM need to indicate the expected condition of the UPS panel as it as noted below.

should be indicated when shutdown.

11. JPM B2.k Original JPM - Take Corrective Action For Main Steam Line Radiation Monitor Changed as In-Plant was replaced. JPM only required verification on indications. Only action was recommended.

to push reset button without any qualifying decision process. The JPM was noted not to be discriminating and of low LOD. The JPM was replaced with actions to vent scram air header, located inside the reactor building.

Replacement JPM - Vent Scram Air Header. Changed as Add a step at the beginning of the JPM to obtain the 29.ESP.03 package from recommended.

the Shift Manager.

FERMI SEPTEMBER 2004 INITIAL LICENSE EXAM JPM COMMENTS Need to re-format the JPM to conform to NRC format (similar to other JPMs). Changed as This JPM was selected by examiners from facility bank and reviewed during recommended.

validation week. However, it was an old JPM, not updated for current plant configuration, and in the wrong format.

In the References, Task Standard, Initiating Cue(s), and Terminating Cue(s), Changed as change from the procedure from 29.ESP.03 Section 6.0" to 29.ESP.03 recommended.

Section 7.0. Also, in the References section, change the title of 29.ESP.03 Section 7.0 to Vent Scram Air Header.

In the Initiating Cue(s), change NASS to CRS to reflect current plant Changed as terminology. recommended.

Change the JPM so that it reflects the change to step 7.3 of 29.ESP.03 Changed as Section 7.0 (i.e., the step now allows either opening valve C1100-F226 or recommended.

disconnecting piping to C11-R013). JPM bank was not updated to the current plant configuration.

In step 7.3 of 29.ESP.03, if the applicant opens valve C1100-F226, the scram Changed as header will NOT vent unless the swagelock cap downstream of valve C1100- recommended.

F226 is also removed. Need proper CUES depending on whether the applicant does/does NOT remove the swagelock cap (i.e., air hissing/NOT hissing out).

12. JPM A1.1 Original JPM - Verification of Offsite Electrical Lineup, was replaced. The Changed as RO/SRO JPM was basically visual verification with little or no actions by the applicant. recommended.

No faults were included, therefore, a fail safe JPM where applicant does not have to do anything and still complete the JPM satisfactorily. The JPM was deleted due to lack of LOD. Replaced with Jet pump operability surveillance that required understanding of meter readings, procedure implementation, calculations, and plotting data on graphs to determine Tech Spec acceptance criteria. In addition, the original JPM was of poor quality. Incorrect step designations. Cue after step 3 repeated bus designation GH.

Step 7 incorrectly repeated the step standards, i.e., verification of procedure steps 1.1.2, 1.1.4, and 1.1.5 was repeated twice. The second designations for the step verification was supposed to be procedure steps 1.2.2, 1.2.4, and 1.2.5. Cue in step 8 noted the wrong Bus designation, it noted Bus 101 when it was required to be Bus 301. Also, in step 8 standard incorrectly noted Bus 101 instead of Bus 301.

Replacement JPM - Jet Pump Operability Test. This was an in-plant JPM, but Changed as it was not marked as plant. Step 7 of JPM incorrectly repeated Pump A when recommended.

it was Pump B.

The NRC data cue sheet for the jet pump indications were incorrectly Appropriately identified repeated twice. Although the actual data was appropriate for the loop A, it and updated during had the wrong designations for jet pump # and indicator designations. exam. Changed as Also, inaccurate validation time based on actual applicant performance. The recommended.

JPM was very involved based on calculations and graph plotting for all 20 jet pumps. More appropriate time would be 30-40 minutes.

13. JPM A1.2 Common - Valve Configuration - tag out of HCU. Need to add in reference the Changed as RO/SRO tag out admin procedure, MOP-12, the requirement to tag drains. recommended.

Remove statements in initiating cue, on the P&IDs, and provide the Changed as attached safety tagging record. Unnecessary. recommended.

Original submittal did not include the tagging record sheet needed to be Changed as provided to the applicant. It was difficult to verify without the actual recommended.

document. Further verification completed during validation week. After facilitys second verification noted two unnecessary tags and that the new tag record developed for different HCU, C1103D090 instead of originally noted C1103D062.

FERMI SEPTEMBER 2004 INITIAL LICENSE EXAM JPM COMMENTS After reviewing reference document, noted that the JPM was a direct look up. Changed as No faults existed and the reference document, procedure 23.106, Control recommended.

Rod Drive Hydraulic System, section 6.10, HCU Isolation for Maintenance on HCU Components, listed the steps necessary for isolating the system.

This would directly reflect to tagging out the system. To accept the JPM, faults were added. Removed from the tagging record the accumulator drain valve required by the reference document MOP-12. Identification of this omission was a critical step, in addition to the other required valves to isolate the system. This made the JPM not a direct look up. Also, examiner noted that this was a similar JPM from 2003, in tagging out the HCU without any faults. Potentially predictable, required faults in the JPM to be acceptable.

During the examination it was identified that the facility made an error in Changed as designating one of the required valves on the tagging record. Valve F104 recommended.

was incorrectly designated for the wrong HCU. It was identified as C1103D066 instead of the correct designation of D090. This error was noted as an additional critical step for applicants to identify the error, due to potential safety concern of tagging the incorrect system.

14. JPM A1.2 Add in the initial conditions that the normal crew compliment on Sunday is at Changed as SRO a minimum IAW shift assignment sheet. Also, remove information that the recommended.

one person assuming the position for the individual leaving is not Fire Brigade qualified. This gives away one of the critical steps that the SRO applicant must identify himself.

Remove the cue in JPM step 3 that notes specific individual was called in by Changed as the RO. This again gives away a critical step where the SRO would be recommended.

required to identify the appropriate operator to call in as a Fire Brigade qualified and IAW the overtime document. Additional critical steps added as appropriate.

As part of the responsibility of the SRO, provide as requested by the SRO Changed as applicant the documents necessary to appropriately identify and make the recommended.

decision to call in an operator within the Tech Spec and admin procedure requirements. Shift staffing sheet, Fire Brigade qualification document, and overtime designation document.

15. JPM A1.3 Original submittall did not include the RWP required for the JPM. It was Changed as RO expected to be a generic RWP for entry into the designated area. Also, the recommended.

initiating cue specifically tells the applicant what to do for the JPM, i.e. the required steps to pass. It indicates the standard for the JPM. Need to reword to enter the area to perform a visual inspection of the system, rather than specifically noting the steps required for an emergency entrance using the RWP. Added steps to require applicant to identify where they need to go, to determine that is a high locked area , and to identify the specific RWP necessary to enter the area. No support from RP desk, and perform the JPM in-plant using the actual RWP. Otherwise, this JPM with given RWP would be a direct look up.

16. JPM A1.4 This JPM too predictable, same JPM as in 2003 NRC exam. The JPMs were Changed as RO written differently, focusing on expanding certain steps; however, the overall recommended.

JPM is identical in actions. Required additional enhancements to insert faults to make it more discriminating, otherwise too predictable and little discriminatory value if performed last year. Added additional critical steps to make the notification with failure of auto dial system. This required the applicant to locate and identify the specific organizations and phone numbers to timely make the required notifications within the time limit. Also, added the requirement that the operator must obtain the Met Tower data using the computer system instead of being given the information.

Remove statement on initiating cue, This is a drill. Add, just in the Changed as statement, Emergency Director has [just] declared a Site Area Emergency... recommended.

Remove the specific information noting the required notification be made within 15 minutes. This is a time critical JPM, and the applicant is expected to know what the time limit is and not be told the time limit.

FERMI SEPTEMBER 2004 INITIAL LICENSE EXAM JPM COMMENTS

17. JPM A1.4 Add in the initiating cue, review.... Also, need to rewrite JPM in proper Changed as SRO format as with the other JPMs. Submitted with incorrect format. Significant recommended..

discussion on this JPM. No actual filled in discharge permit on original Although, during the submittal, During validation noted errors on the filled in discharge permit. Item exam noted that the C was originally marked N/A; however, after review it was identified that it applicants also should be marked as Outfall Affected 002. Corrected for actual exam. designated a specific Added additional critical steps to identify that the discharge is subject to time in hours to note radiological restrictions. Also, questionable of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit. Examiners the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time limit, noted that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would likely be specified in actual time and not just the and not just the next following day for the required critical step to note the permit expiration date. day.

Verified with radwaste that only the next day was required and not the specific hours to note 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time limit.

18. JPM A1.5 Original JPM only had the applicant determine the implementation time for Changed as SRO the PARs to evacuate the given designated areas. Based only on this recommended.

expectation it appeared to be only a direct look up. There was no decision making by the SRO applicant on the safety information of the PARs. That is the PAR was given as part of the initial conditions. Given the PARs, the applicant only had to use the tables in the Emergency Plan to identify the time estimate and the estimated population. Further review resulted in identifying that the PARs given was not correct. Although the action to utilize the tables was considered an adequate evolution of use of procedures, it was not readily identified as a required or expected responsibility of the SRO. Even if the State requested such information, it would not have been an adequate critical safety item by itself to determine acceptable performance of the applicant. Required additional emphasis to have the applicant identify the appropriate PARs based on new plant conditions. Subject to identifying the correct PARs , required the remainder of the JPM to evaluate the use of the Emergency Plan to determine the evacuation times and population.

Rewrite JPM to require PARs based on new plant data. Also include time Changed as critical condition for identifying PARs and making the initial notification. recommended.

Note: General comment on outline, the facility licensee through outline submittal noted the wrong dates of exam (9/13/2004). Correct date was 9/20/2004.